KEY TAKEAWAYS

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REACH applies to articles (finished parts) if they contain SVHCs above 0.1% w/w concentration — not just chemical suppliers.

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Substance of Very High Concern (SVHC) list is updated twice yearly — your compliance status can change without any design change.

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Downstream suppliers must be proactively notified when an SVHC exceeds threshold, even if no SDS is required.

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Material certifications and RoHS compliance do not automatically equal REACH compliance — they are separate frameworks.

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Document your supply chain substance data now — retroactive traceability on legacy parts is expensive and often incomplete.

REACH — Registration, Evaluation, Authorisation and Restriction of Chemicals — is an EU regulation (EC No 1907/2006) that governs the use of chemical substances in products sold within the European Economic Area. It is administered by the European Chemicals Agency (ECHA). Unlike RoHS, which targets a specific list of restricted substances in electrical equipment, REACH is a broader framework that applies to substances on their own, in mixtures, and in articles — which includes virtually every manufactured part. The regulation places the burden of proof on manufacturers and importers to demonstrate safe use. For engineers sourcing precision components, this means REACH is not just a chemistry department problem. It directly affects material selection, surface finishing choices, plating specifications, and supplier qualification. If a part contains a Substance of Very High Concern (SVHC) above the 0.1% weight-by-weight threshold, obligations are triggered — regardless of whether that substance serves a functional purpose or is incidental to manufacturing. Understanding where REACH responsibilities sit in your supply chain is the first step toward durable compliance.

REACH is not just for chemical companies. If you manufacture or import physical parts into the EU, you are an ‘article producer’ under REACH and carry compliance obligations.

The Candidate List of Substances of Very High Concern is the operational core of REACH for most manufacturers. ECHA updates this list twice per year — typically in January and July — adding substances identified as carcinogenic, mutagenic, reprotoxic (CMR), persistent/bioaccumulative/toxic (PBT), or of equivalent concern. As of 2024, the Candidate List contains over 240 substances. This matters operationally because your parts can fall out of compliance without any design change. A surface treatment or alloy additive that was clean last year may now be flagged. Common SVHC triggers in machined and fabricated components include lead in brass alloys, hexavalent chromium from hard chrome plating, cadmium in plating and solders, certain phthalates in elastomeric seals or gaskets, and boric acid compounds used in some metalworking fluids. The 0.1% threshold applies per substance per article — not across the finished assembly. A small brass fitting that is part of a larger system must be evaluated on its own weight. Procurement teams need a live monitoring process tied to ECHA updates, not a one-time compliance audit.

⚠ The Candidate List is updated twice per year. A static REACH compliance review done at product launch is not sufficient for ongoing market access.

When a manufactured article contains an SVHC above 0.1% w/w, two primary obligations apply. First, supply chain communication: suppliers must provide sufficient information to allow safe use to any downstream recipient requesting it. This must be provided free of charge within 45 days of a request. Second, consumer notification: if a product containing an SVHC above threshold is supplied to consumers, they must be notified upon request — again within 45 days. Beyond these, if your annual production or import volume of an SVHC-containing article exceeds one metric ton per year, you may have a notification obligation to ECHA under Article 7(2). This notification requires identifying the substance, its concentration range, tonnage, and intended use. Importantly, if the exposure to humans and the environment can be excluded during normal or reasonably foreseeable conditions of use, this notification may not be required — but that exclusion must be formally justified, not assumed. These obligations fall on whoever places the article on the EU market. If you are a US manufacturer exporting to EU customers, your EU-based importer or distributor may be the responsible party — but that does not eliminate the need for your upstream substance data to be accurate and available.

These two frameworks are frequently conflated, and that confusion creates compliance gaps. RoHS (Restriction of Hazardous Substances Directive, 2011/65/EU) restricts specific substances in electrical and electronic equipment — specifically lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates added under RoHS 3. RoHS compliance certificates are scoped to that equipment category and those specific substances. REACH is broader in scope, applies across all product categories, and covers a continuously evolving Candidate List. A part can be fully RoHS compliant and still contain SVHCs that trigger REACH obligations. Conversely, some REACH restrictions under Annex XVII apply to substances not covered by RoHS. The other common confusion is between REACH and Safety Data Sheets (SDS). SDS requirements apply to substances and mixtures — not articles. Your material supplier’s SDS satisfies their obligation, not yours as an article producer. You need to trace substances through your manufacturing process — including plating baths, conversion coatings, and secondary treatments — and confirm concentrations in the final article. A certificate of conformance from a supplier stating ‘REACH compliant’ should always be backed by actual substance disclosure data, not just a declaration.

A supplier’s ‘REACH compliant’ declaration is only as good as the substance data behind it. Always request SVHC substance disclosure — not just a compliance certificate.

Certain manufacturing processes carry elevated REACH risk and deserve closer scrutiny during design and supplier qualification. Surface finishing is the highest-risk category. Hard chrome plating (hexavalent chromium), cadmium plating, and some conversion coatings historically used chromate compounds — all SVHC-flagged. Trivalent chrome alternatives exist and are widely used in aerospace applications as direct replacements. Alloy composition is the second major risk area. Free-machining brass alloys (C36000, for example) contain up to 3.5% lead by weight — well above the 0.1% SVHC threshold. Lead-free brass alternatives such as C69300 or bismuth alloys are commercially available but may require process parameter adjustments. Elastomers, seals, and adhesives used in assembled parts can introduce phthalates or boric acid derivatives. Even lubricants and rust-preventative coatings applied post-machining may contribute to SVHC load in the finished article. Metal 3D printing feedstocks — particularly nickel-based superalloy powders — may contain cobalt compounds that appear on the Candidate List. Any shop working in these materials needs substance-level data from their powder suppliers, not just material grade certificates. A thorough design-for-compliance review at the process selection stage is far less expensive than a reformulation effort after tooling.

REACH compliance for manufactured parts is fundamentally a data problem. You need substance-level information from every tier of your supply chain — raw material producers, plating shops, secondary processors — and you need it in a format that survives supplier transitions and Candidate List updates. Start with a structured substance disclosure request process. Use IPC-1752A Class D or equivalent XML-based formats where possible — these allow machine-readable substance data that integrates into compliance management platforms. For each critical material and finish, maintain a current SVHC screening result that maps against the Candidate List version in effect at time of shipment. Engage suppliers contractually. A purchase order should include language requiring SVHC notification within a defined window (30 days is standard) if any incoming material change could affect SVHC status. This is especially important for plating and finishing subcontractors who may change chemistry formulations without customer notification. Working with a sourcing partner that maintains a qualified, documented supplier network simplifies this considerably. Nimble’s certified partner network operates under ISO 9001 and AS9100 quality systems, which include supplier qualification and incoming material documentation requirements that directly support REACH traceability. That infrastructure doesn’t replace your compliance program, but it reduces the data-gathering burden significantly when sourcing machined or fabricated components.

IPC-1752A Class D provides a standardized, machine-readable format for SVHC substance disclosure — request it from suppliers rather than accepting narrative declarations.

Beyond the Candidate List, REACH has two enforcement mechanisms that can prohibit or restrict substance use entirely: Annex XIV (Authorisation List) and Annex XVII (Restriction List). Substances on Annex XIV require affirmative authorisation from ECHA before they can continue to be used or placed on the EU market. Once a substance is listed, a sunset date is set after which use is prohibited unless specific authorisation is granted. Hexavalent chromium compounds used in surface treatment are a prominent example — they have been listed, and many aerospace and defense manufacturers have been navigating authorisation applications or reformulation programs for years. Annex XVII contains restrictions — specific prohibitions on manufacture, use, or placing on the market, often scoped to particular applications or concentration levels. Cadmium plating on metal articles, for example, is restricted under Annex XVII Entry 23, with specific exemptions for aerospace and military applications. If your parts are destined for aerospace platforms, those exemptions may apply — but they must be documented and you must be aware of the precise scope of the exemption. Both lists require ongoing monitoring. An Annex XIV listing often begins years before the sunset date, giving manufacturers time to seek authorisation or qualify alternatives — but only if they are watching ECHA activity systematically.

⚠ Annex XIV sunset dates are fixed deadlines. If you are using hard chrome or other listed substances in EU-facing products, check current authorisation status now — not at your next compliance review cycle.

Compliance is built in design, not bolted on at the shipping dock. Start by integrating REACH screening into your material selection process. Before finalizing a finish specification or alloy call-out on a drawing, run the candidate materials against the current ECHA Candidate List. This takes minutes and can prevent expensive re-qualification later. Second, establish a master substance inventory for each product line. This document should map every material and process input to its SVHC status, concentration estimate in the finished article, and the Candidate List version used for that assessment. Review it against each new ECHA update. Third, make REACH data a required deliverable in your supplier qualification process — alongside first article inspection reports, material certifications, and process capability data. For teams quoting new components, Nimble provides a free DFM review with every order — a practical checkpoint to flag high-risk material or finish specifications before tooling is cut. While DFM is not a REACH audit, catching a hard chrome call-out or a high-lead alloy spec early in the process gives your team options. Finally, keep records. ECHA and EU market surveillance authorities can request compliance documentation. A well-maintained substance database is your first line of defense and your clearest evidence of due diligence.

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